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Canada Considering Changes to Tents and Toys Regulations

Health Canada is seeking public input through 23 March on a proposal to amend the current labelling and flammability requirements for tents and make related changes to the Toys Regulations. The Tents Regulations currently apply to portable shelters made of fabric or other pliable materials, such as camping tents, ice-fishing tents and dining shelters. Children’s tents are also subject to these requirements regardless of whether they are intended to provide shelter. Excluded from these requirements are tents subject to the National Building Code of Canada as well as canopies, awnings, tarps, tent trailers and air-supported structures.

Canadian authorities indicate that the current standards for tents were developed to address flammability issues of cotton canvas tents. However, most tents in today's market are made of synthetic, lighter-weight materials such as polyester and nylon, with different burning properties than cotton canvas. Accordingly, Health Canada officials believe the current requirements are less suited to address the flammability risks of tents available to Canadian consumers today. Health Canada adds that the current regulations may also inhibit industry from developing and using tent materials that would likely be deemed safe from a risk perspective but cannot meet the current regulatory requirements.

Among other things, the revision would entail replacing the current requirements with the requirements set out in CAN/CGSB-182.1, a new standard developed by the Canadian General Standards Board that is expected to be published on 31 March. Key changes to the regulations would include:

  • aligning the product scope of the Tents Regulations with the product scope of CAN/CGSB-182.1, which would include tent trailers and exclude tents intended for indoor use only;
  • providing a more detailed definition of a tent to better help industry determine whether or not a product is included in the scope;
  • setting out one weathering procedure (fluorescent ultraviolet and condensation procedure, with water spray) instead of three (carbon arc and xenon lamp options have been removed) to improve consistency in results and align with the most commonly used laboratory equipment;
  • adopting one flammability test method for all tent materials (vertical test) instead of separate test methods for flooring materials (horizontal test) and wall/top materials (vertical test) to streamline testing, reduce costs and support product innovation;
  • increasing the number of specimens cut from each test material and subjected to the vertical test under each of three test conditions (untreated (as sold), after leaching and after weathering) from eight to ten (total of 30 specimens from each test material) to address variability in results;
  • introducing various performance requirements while removing certain other requirements;
  • adopting a safety alert symbol as well as cautionary statements on keeping exits clear, not applying foreign substances to the tent and ensuring adequate ventilation; and
  • requiring labels on children’s tents to be prominently displayed on the outside of the product.

As part of this regulatory effort, Health Canada would also amend the Toys Regulations to continue regulating the flammability and fire-safety labelling of children’s play tents intended for indoor use only. Additionally, the agency is considering prohibiting or restricting the use of chemical flame retardants in tents under the Tents Regulations as well as in play tents and possibly other toys subject to flammability requirements under the Toys Regulations, including dolls, plush toys and soft toys. Health Canada indicates that preliminary testing by its product safety laboratory using a number of common tent materials has shown that the flammability requirements proposed under CAN/CGSB-182.1 are likely to be met without flame retardant use.

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